Bloom v. Azar, No. 18-2390 (2d Cir. 2020)
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Plaintiff, a Medicare beneficiary who uses a Continuous Glucose Monitoring device (CGM) to manage his Type I diabetes, sought Medicare coverage to offset the costs associated with his CGM. After the Medicare Appeals Council rejected plaintiff's requests for coverage, he challenged the adverse decisions in federal court. The district court concluded that two of the three challenged decisions failed to meet the $1,500 amount-in-controversy threshold for federal court jurisdiction and that the Medicare Act did not permit plaintiff to cure the jurisdictional deficiency by aggregating the three separate amounts.
The Second Circuit held, based on the text of the statute and reinforced by its regulatory and legislative history, that the Medicare Act does not prohibit plaintiff from aggregating his claims for the first time in district court. Therefore, the district court erred in refusing to let plaintiff aggregate his claims to satisfy the Act's amount-in-controversy requirement. The court vacated the district court's judgment and remanded for further proceedings.
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